Virginia Regulatory Town Hall
Agency
Department of Environmental Quality
 
Board
Air Pollution Control Board
 
Guidance Document Change: DEQ Guidance Memo APG-578 addresses the use of emergency generators in the case of “sudden and reasonably unforeseeable events” as the result of a planned electric outage.
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11/22/25  6:19 pm
Commenter: Chris Tandy

Don't relax standards on data center generators
 

DEQ - I do not support any expansion of data centers ability to run any fossil-fuel based generation on site. Having reviewed quite a few air pollution permits, I'm alarmed at the amount of air pollution already permitted for data centers. Considering PJM issued "Pre-Emergency Load Mgmt Reduction Actions" this year resulting in increased data center generator use in Virginia, I think we're already seeing a weakening of what's considered an "emergency" generator use. If needed additional generation is entirely foreseeable such as at times of peak load, then it doesn't seem like an emergency, but rather a planned outage. These guidelines seem to define those planned outages as emergencies, which I believe is incorrect. 

In Loudoun County where I live, over 500 tons per year of PM2.5 has already been permitted via Article 6 Minor NSR permits, requiring no public notice or hearing, for a pollution type that has consequences to public health such as respiratory disorders, heart disease, and adverse birth outcomes like low birth weight and premature birth. This is already unacceptable, and now DEQ seemingly proposes to make things worse. 
 
With respect, please regulate air pollution in a manner that supports public health and reducing greenhouse gas emissions as top priorities, rather than enabling pollution. I would also ask that priority be given to supporting the Virginia Clean Economy Act, which the JLARC report on data centers mentions is getting more challenging to meet because of energy demand from data centers. 
 
https://emergencyprocedures.pjm.com/ep/pages/dashboard.jsf
https://www.loudounnow.com/news/heat-wave-prompts-increased-data-center-generator-use-turner-pushes-for-tier-4-upgrades/article_60a48bda-dc50-4d1a-8b16-399cd4340350.html
https://jlarc.virginia.gov/pdfs/reports/Rpt598.pdf
CommentID: 237923